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pchapman

What FAA regulation requires following manufacturers instructions?

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I'm trying to understand some of the US Federal Air Regs pertaining to skydiving and rigging.

Just which regulation in the USA requires riggers to follow manufacturers instructions?

This requirement is often at the heart of discussions about Cypres maintenance, repacking old reserves, and following instruction manuals.

I see that FAR 65.129 (e) says that
"No certificated parachute rigger may--
[…]
(e) Pack, maintain, or alter a parachute in any manner that deviates from procedures approved by the Administrator or the manufacturer of the
parachute; "

Is that the regulation that is referred to so often, such as when people discuss why a rigger isn't allowed to repack a reserve with an expired Cypres battery?

Or is there another reg that also applies?

The term "parachute" in the quote must refer to the whole 'approved system' -- but where is that definition? (I know the main chute is not included in the requirements, as stated in FAR 65.125 (c))

And in the case of Cypres batteries etc, what rule makes the AAD part of the approved system?

AC 105 on parachuting mentions that
"The FAA does not approve AAD's. They do approve the installation which is submitted with the manufacturer's TSO paperwork."
So that doesn't address the battery issue.

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Is that the regulation that is referred to so often, such as when people discuss why a rigger isn't allowed to repack a reserve with an expired Cypres battery?



Quote

And in the case of Cypres batteries etc, what rule makes the AAD part of the approved system?



"§105.43 Use of single-harness, dual-parachute systems.
(c) If installed, the automatic activation device must be maintained in accordance with manufacturer instructions for that automatic activation device."

Quote

Just which regulation in the USA requires riggers to follow manufacturers instructions?



"§65.129 Performance standards.
(f) Exercise the privileges of his certificate and type rating unless he understands the current manufacturer's instructions for the operation involved and has -- "

From AC-65-5B:

"If an FAA inspector gives the oral and practical tests, the necessary facilities and equipment must be furnished or arranged for by the applicant. The applicant will be expected to furnish:
(1) a smooth-top table, at least 3 feet wide by 40 feet long,
(2) provisions for drying and airing parachutes,
(3) manufacturer's instructions, and the tools and equipment used to pack and maintain the types of parachutes for which a rating is sought, and
(4) adequate housing facilities to perform the duties of a parachute rigger and to protect the tools and equipment. At least one approved parachute of each type for which a rating is sought must be available for the oral and practical tests."

Derek

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Thanks for the info. There are stilll some issues in my mind though.

Quote

"§105.43 Use of single-harness, dual-parachute systems.
(c) If installed, the automatic activation device must be maintained in accordance with manufacturer instructions for that automatic activation device.



Ah, FAR 105 not AC 105. So AAD's are a special case, specifically mentioned.

Regarding following manufacturer's instructions:
Quote


"§65.129 Performance standards.
(f) Exercise the privileges of his certificate and type rating unless he understands the current manufacturer's instructions for the operation involved and has -- "



But that doesn't say the rigger has to follow manufacturers' instructions... just to UNDERSTAND them. Is there some other definition or rule that clarifies or adds to that?

If we can't find any other rule to quote, one would have to conclude that all those arguments about following manufacturers' instructions go out the window. The exception is cases like AADs that have specific rules in the FARs.

Quote


"The applicant will be expected to furnish:
[...]
(3) manufacturer's instructions, and the tools



Interesting to know, but that refers to taking rigging tests, and not rigging in general.

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But that doesn't say the rigger has to follow manufacturers' instructions... just to UNDERSTAND them. Is there some other definition or rule that clarifies or adds to that?

If we can't find any other rule to quote, one would have to conclude that all those arguments about following manufacturers' instructions go out the window.



Try 65.129 (Performance Standards): "No certificated parachute rigger may-(e) Pack, maintain, or alter a parachute in any manner that deviates from procedures approved by the Administrator or the manufacturer of the parachute..."

Stop looking for loopholes. We are expected to know what the manufacturers require, and we are expected to follow their instructions. If you have a problem with a specific instruction or requirement, contact the manufacturer directly for clarification or a written opinion regarding your intent.

Tom Buchanan
Senior Parachute Rigger
S&TA
Author JUMP! Skydiving Made Fun and Easy
Tom Buchanan
Instructor Emeritus
Comm Pilot MSEL,G
Author: JUMP! Skydiving Made Fun and Easy

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But that doesn't say the rigger has to follow manufacturers' instructions... just to UNDERSTAND them. Is there some other definition or rule that clarifies or adds to that?



"§65.129 Performance standards.
(e) Pack, maintain, or alter a parachute in any manner that deviates from procedures approved by the Administrator or the manufacturer of the parachute; or "


Derek

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Try 65.129 (Performance Standards): "No certificated parachute rigger may-(e) Pack, maintain, or alter a parachute in any manner that deviates from procedures approved by the Administrator or the manufacturer of the parachute..."



Guess that is the only reg. It was staring me in the face -- I had it in my original post.

It is sometimes good to 'go back to first principles', or in this case, the federal regs, to understand an issue.

As for looking for loopholes, yeah, I would. I'm no fan of the reg. I'll save that discussion mostly for another time. Just one sarcastic comment for now (NOT directed at those who helped out with responses to my question!):

Be careful you don't get your rigger's ticket pulled because you leave a customer's rig in non environmentally controlled room. The manual for one modern & very solidly built reserve says that "When the parachute is not used it must be stored in a room where the temperature is kept between 15 and 30 [degrees C]. And where the humidity is between 15% and 70%."

Remember, riggers must comply!

Over and out.

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Just one sarcastic comment for now...
Be careful you don't get your rigger's ticket pulled because you leave a customer's rig in non environmentally controlled room. The manual for one modern & very solidly built reserve says that "When the parachute is not used it must be stored in a room where the temperature is kept between 15 and 30 [degrees C]. And where the humidity is between 15% and 70%."



That does sound excessive, and I do recognize the sarcasm in your comment. With that said, it's probably not a good idea for a rigger to store a rig in the trunk of his car. As you read a manufacturers manual try thinking of the way we abuse equipment and the objectives of the instructions. The manufacturers instructions generally make sense.

-tom buchanan
Tom Buchanan
Instructor Emeritus
Comm Pilot MSEL,G
Author: JUMP! Skydiving Made Fun and Easy

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Stop looking for loop holes.
Those quotes from FARs and ACs are a subtle admission by the FAA that no desk-bound bureaucrat can hope to stay up to date on all the subtlties of skydiving gear. The people who manufacturer and repack the gear -every day - are the best people to ask.

In most other countries (i.e. Canada) the federal government delegates most of the responsibility for regulating parachutes on the National Aero Club (i.e. Aero Club of Canada, which delegates to the Canadian Sport Parachuting Association).

In other words, if you want to understand the finer points of maintaining an airplane built by Cessna, don't waste your time asking the FAA.
Ask Cessna!

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I am un-able also, to find in the FAR's where a parachute rigger 'must follow manufacturer's instructions'. In the instruction manuals put-out by the various manufacturer's, supplied with main and reserve parachutes as well as with parachute harness-containers, it states there, that their instructions must be followed. These instructions are supported by the FAA. To not follow the instructions is asking for trouble. [:/]

Hope, this helps.

Chuck

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